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Submitted by Naoyuki Toyoshima, Chairperson of Radiation Control Committee, The Federation of Electric Power Companies of JAPAN
   Commenting on behalf of the organisation
Document Optimisation of radiological protection
 
1. General Comment on the Whole Foundation Document
This foundation document does not reflect many comments to the draft version of a new ICRP recommendation that was released last year.
ICRP should issue answers in a concrete manner to many common comments such as concepts of "dose constraint" and "intervention".

2. Comment on the Selection of Protection Options
Paragraph 32 shows a representative list of useful attributes to be considered to select the best protection options. However, the list may be misinterpreted to mean that all the attributes shall be taken into consideration. Therefore, it should be written expressly that it is enough to select necessary attributes depending on the situation.

3. Comment on BAT Techniques
Paragraph 39 describes emission reduction by BAT techniques, but the definition of BAT techniques and their definite concept are unclear. Therefore, as nuclear operators, we can not accept BAT techniques unless proper use of ALARA and BAT is made clear.

4. Comment on the Endpoint of Optimisation
Paragraph 56 writes that the endpoint of optimisation represents "the best level of protection that can be achieved given the circumstances." When coordination with ALARA is taken into consideration, however, the endpoint of optimisation should be written as "the protection level that can be achieved reasonably under certain circumstances." In addition, concerning the endpoint of optimisation, the methods how to develop definite objectives and their interpretation should be described in the annex (A1).

5. Comment on Occupational Dose Constraints
In Japan, a system to manage individual doses uniformly is established so that statutory regulations are kept concerning the nuclear operators who operate nuclear power stations, test and research reactor facilities, nuclear fuel processing facilities, nuclear fuel reprocessing facilities, radioactive waste disposal facilities, etc. And in Japan, there are very few workers who go around multiple countries, for whom "the allocation of doses" must be considered. Therefore, management by "dose constraint" is not necessary and management by "dose limit" is enough. These circumstances should be written expressly as the cases where the introduction of dose constraints is not necessary.

6. Comment on Public Dose Constraints
If dose constraints to the public are adopted, the document should write expressly the case where there is a potential that the public may receive exposure at multiple nuclear facilities.